The U.S. Department of Commerce has reopened a completed antidumping duty administrative review of carbon and alloy steel wire rod from South Korea after receiving evidence indicating possible false statements.
The original review resulted in a 0.00% weighted-average dumping margin for POSCO/POSCO International Corporation, the sole mandatory respondent.
Commerce will now reopen the record and reconsider those results. U.S. Customs and Border Protection will be instructed to suspend liquidation of entries covered by the review while the reconsideration is underway.
Why Commerce Reopened the Review
Commerce published the final results of the 2023-2024 administrative review on April 7, 2026, assigning POSCO/POSCO International a zero dumping margin.
During the subsequent 2024-2025 review, Commerce received evidence indicating that possible false statements may have been made in both the ongoing review and the previously completed 2023-2024 proceeding.
Commerce has not publicly concluded that fraud occurred. It is reopening the earlier review because the new evidence may affect the integrity of the final results.
The agency cited federal court precedent recognizing Commerce’s authority to reconsider an administrative-review determination when information obtained within a reasonable period indicates that the result may have been tainted by fraud.
A Zero Margin May No Longer Be the Final Result
The 0.00% margin previously assigned to POSCO/POSCO International is now subject to reconsideration.
Commerce could ultimately:
- Confirm the original zero margin
- Calculate a new dumping margin
- Apply facts available or adverse inferences
- Issue revised assessment instructions
- Update the applicable cash-deposit rate
The notice does not announce a replacement rate or predict the result of the reopened review.
Importers should not assume that the reopening automatically creates a new duty rate. However, they should recognize that entries previously expected to liquidate without antidumping duties may now remain open and could receive different treatment after Commerce completes its reconsideration.
CBP Will Suspend Liquidation of Covered Entries
Commerce intends to instruct CBP to suspend liquidation of entries covered by the 2023-2024 review during the reconsideration.
Suspension of liquidation prevents CBP from finalizing the antidumping duty liability for those entries. The importer’s final liability will remain unresolved until Commerce completes the proceeding and issues appropriate assessment instructions.
At the conclusion of the reconsideration, Commerce may issue new instructions no earlier than 35 days after publication of its reconsidered results in the Federal Register.
If Commerce changes the applicable cash-deposit rate and that rate has not been superseded by a subsequent administrative review, it also intends to update the deposit requirement for future entries.
Why This Matters to Importers
Antidumping duties are assessed retrospectively. The importer of record remains responsible for the final amount owed, even when merchandise was entered using a 0.00% deposit rate.
A revised result could affect:
- Entries that remain unliquidated from the review period
- Antidumping duty accruals
- Financial reserves
- Customs-bond exposure
- Supplier contracts
- Reimbursement certifications
- Future cash-deposit requirements
- Import pricing and sourcing decisions
Importers should not assume that the foreign producer or exporter will absorb any additional liability. U.S. antidumping law generally prohibits reimbursement of antidumping duties by the producer or exporter, and importers may be required to certify that reimbursement has not occurred.
Commerce Is Not Yet Accepting Comments
Commerce is not currently requesting information or comments from interested parties.
The agency plans to issue a separate memorandum establishing the procedural steps for the reconsideration, including any deadlines for submitting information or arguments.
Importers, exporters, and other interested parties should monitor the proceeding closely so they do not miss a future opportunity to participate.
Broader Implications for Administrative Reviews
The reopening demonstrates that a completed administrative review is not necessarily immune from reconsideration when later evidence raises concerns about the integrity of the record.
It also highlights the retrospective risk inherent in antidumping proceedings. Even when a review produces a zero margin, importers should preserve supplier records, entry data, pricing documentation, and financial reserves until the relevant entries have liquidated and the period for further agency or judicial action has passed.
Companies should also conduct independent due diligence rather than relying exclusively on representations from the foreign supplier.
What Importers Should Do
Importers of Korean steel wire rod should:
- Identify entries associated with POSCO or POSCO International during the affected review period.
- Determine which entries remain unliquidated.
- Review ACE data for changes in liquidation status.
- Confirm that accounting reserves reflect the possibility of revised duty liability.
- Review contracts addressing responsibility for antidumping duties.
- Confirm compliance with antidumping duty reimbursement requirements.
- Preserve entry records, purchase documents, supplier communications, and pricing information.
- Monitor Commerce’s procedural memorandum and future submission deadlines.
- Review customs-bond sufficiency if a new deposit rate becomes possible.
- Evaluate whether current sourcing decisions depend on the existing 0.00% rate.
The reopening does not establish that additional duties will ultimately be owed. It does, however, restore uncertainty to entries that importers may previously have expected to liquidate at a zero antidumping rate.
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References
Tokyo Kikai Seisakusho, Ltd. v. United States, 529 F.3d 1352 (Fed. Cir. 2008)
